ILMA Compoundings – December 2019 - 16

Global Compliance
There are several global requirements that ILMA members
need to watch in the year ahead. China is in the process of
a complete rewrite of the country's chemical control laws,
Eggenschwiler said. "The process is going to change substantially. Regulatory restrictions are likely to increase among
different categories," he said.
In addition, Argentina is expected to make announcements related to its chemical regulations in 2020.
Eggenschwiler said the industry had been expecting them
in 2019, but there hasn't been a public announcement.
"They've gone silent," he said. "It has already been a year
since they issued their memorandum of understanding."

Manufacturers should also spend 2020 ramping up for
poison control center notifications in Europe, which will
take effect in January 2021. "It is going to require some
consistent attention to make sure folks can comply in time.
They have to evaluate where each of their chemicals is going
within the European economic area," Eggenschwiler said.
Manufacturers have to register with each of the member
states or areas covered by the Poison Centres Notification
regulation. "It is kind of a registration with the poison
centers, so they have all of the information about the
chemicals and the emergency response organizations have
the contact information for the manufacturer sending it in,"
Eggenschwiler said.
The complicating aspect is that manufacturers have to ensure
they cover not only the member states but also areas where their
product is expected to enter. "You may send it to a customer
in Germany, for instance, but then that customer could be
sending it into other areas," Eggenschwiler explained.
South Korea's Act on Registration and Evaluation of
Chemical Substances (K-REACH) goes into effect in January. "The new registration requirements will begin for those
who have CMRs - carcinogens, mutagens and reproductions - in any amount," Eggenschweiler said. "If somebody
did not submit a pre-registration, they need to get on it
right away. If they don't, they could be limited to an amount
of less than 1 ton for a period of years if they don't get that
late pre-registration in."
Eggenschwiler added that within South Korea, K-BPR, the
consumer and biocides law, is in effect, and people need to
make sure that they are either pre-notified for K-BPR or they
need to submit a request for the opportunity to late pre-notify.
Australia is continuing to work on its chemical regulations,
and that work will continue into 2020. "Their whole system
has been in the process of changing over the last three years at
least," Eggenschweiler said. "Some of them are optionally effective now. The rest are in the process of being implemented."

Employment Issues
Operationally, ILMA members may face higher wages for
employees. Matt Levetown, ILMA's associate counsel, said more
employees will be eligible for overtime beginning in 2020. The
U.S. Department of Labor has issued a rule, the Fair Labor
Standards Act, that will take effect on Jan. 1, making more than
1 million American workers eligible for overtime.
"Labor announced a rule raising the minimum salary for
overtime to $35,308. It currently is at $23,660," Levetown
said, adding that the level hadn't been changed since 2002.
Levetown said there won't be any change to the job duties
test, and exemption from overtime is based on the nature
of work.

DECEMBER 2019

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ILMA Compoundings – December 2019

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